The focus was clearly on evolving Export Control Reform (ECR). There was also significant emphasis on enforcement and individual accountability. All of the presentations are available on the BIS website at http://www.bis.doc.gov/seminarsandtraining/update2012/presentations.htm?goback=%2Egde_2636417_member_136833.
I was surprised each day at how many attendees who were not tuned-in to what is going on with ECR and particularly the migration of items, parts, pieces, components… from the US Munitions List to the Commerce Control List and the related significant impact and implications. Based on many questions asked or submitted there are many not keeping track of the relevant Federal Register (FR) notices.
The concern is, if people attending Update do not know what is going on to the degree they should, what about all those who were not there? Are they out of the loop? Are they overwhelmed with FR notices? Are they still skeptical about ECR? Are they waiting for the rules to actually take effect?
There is no doubt. ECR is having and will have dramatic impact with a long list of implications. Thus, it is essential to be well aware of what is going on, provide the US Government (USG) your perspective and prepare for the future.
When it comes to FR notices of proposed rulemaking, the resounding message from USG speakers is to strongly encourage everyone with any vested interest across the trade compliance industry to thoroughly consider the Proposed Rules and respond accordingly. Your organization’s views are vital to the process and needed to arrive at the best possible Final Rule.
If you are a small organization do NOT discount or underestimate the value of your unique perspective. Please take the time to analyze the impact and implications to your organization and provide feedback. Do not assume your organization’s views are not important, will not carry any weight or get lost in the pile with other submissions. The Department of Commerce really wants to know. Do not let your organization and you get left out!
The BIS staff guarantees they will read and equitably consider any and all inputs and factor them into the discussions and deliberations when putting together Final Rules. They have consistently proven they do exactly that. Please take the time to do your homework and contribute productively to the way ahead, otherwise you will not have any firm foundation to complain about ECR outcomes detrimental to you or your organization.
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